The future of higher education and the Higher Education Act 2004: Regulatory Impact Assessment
CHAPTER 1 - INTRODUCTION
1. This Regulatory Impact Assessment (RiA) covers the proposals in the White Paper, ‘ The Future of Higher Education’ published in January 2003, , and the proposals in the Higher Education Act 2004. 2. For the most part, the provisions of the Act flow from those originally put forward in the White Paper, some of which have been modified by subsequent policy documents – notably ‘ Widening Participation in Higher Education’ published in March 2003. For this reason, the RiA mirrors the , structure of the White Paper, and looks at its proposals chapter by chapter. They map onto the Act as below: Arts and Humanities Research Board Review of Student Complaints Student fees in HE Office of Fair Access Effect of Bankruptcy Chapter 2 Chapter 4 Chapter 7 Chapter 6 Chapter 7
3. Two measures in the Act – on Devolving Responsibility to Wales and Transfer of Information - were not covered in the White Paper. They are in Chapter 8 of the RiA. 4. The RiA attempts to outline the potential costs and benefits of the disaggregated proposals. However, as the text tries to make clear, the White Paper put forward a coherent package of measures, and needs also to be seen as a whole.
CHAPTER 2 – RESEARCH EXCELLENCE
We want to think carefully about the way Government investment in research is managed and funding distributed, so that it works in the most effective way. To do this, we will take three important steps: * Target resources in our very best research institutions, enabling them to compete effectively with the world’ best universities s * Make sure that the very best individual departments are not neglected, by making a clearer distinction between the strong and the strongest * Encourage the formation of consortia, provide extra funding for research in larger, better managed research units, and develop criteria to judge the strength of collaborative work Objectives and Options 1. The overall policy objective is to improve the amount of high quality research by concentrating resources more effectively, to ensure its long term sustainability and international competitiveness. 2. There is evidence of huge pressure on research funds. For example, a report commissioned from JM Consulting by HEFCE in 2001 suggested there might be a research infrastructure backlog of around £3.2bn, plus a need to double expenditure on maintenance. The 1998 Transparency Review and other reports showed that universities were not recovering the full economic costs of the research they undertook. A further updated study of university infrastructure for science research and the Science Research investment Fund in May 2004 concludes that, ‘ will take some years of consistent it investment to achieve a situation where broadly the whole infrastructure is satisfactory .’Irrespective of the precise figures, there is plainly a backlog of demand for essential resources across the sector, and historic underinvestment in infrastructure, meaning that the current spread of research is not sustainable. 3. We also know from international comparisons that our major competitors continue to invest and concentrate resources to improve the volume and quality of their research. Countries such as Germany, the Netherlands and the USA, concentrate their research in relatively few institutions. Similarly, the Chinese government is planning to concentrate research funds through the creation of ten world-class universities, and in India there is a national Institute of Technology, on five sites across the country. 4. We believe that we must also ensure better use of inevitably limited research funds. 5. The first two elements of our objective are to invest more in our very best departments and institutions. This means primarily the research staff
who are in departments rated 5 or 5*, following the 2001 Research Assessment Exercise (RAE). The numbers of these staff have doubled between 1996 and 2001, and now represent 55% of all researchers. Such increases require an adjustment to the distribution of the total funding pot, or there would be significantly less resource for each of these researchers. HEFCE has therefore ensured that the unit of funding for these top quality staff has been restored in real terms to its 2001 level. 6. We made available an additional £20 million in 2003-04 to the very best 5* departments - i.e. those achieving 5* in both 1996 and 2001 RAEs (known as ‘ double 5*’ Additionally in 2004-05 departments which achieved ). 5* in 2001 while maintaining or increasing their volume will also be funded at this higher level. This doubles the number of ‘ best 5*-rated’departments to be funded to 2007. 7. The third element of our broad objective is to increase the incentives for collaboration between departments and institutions. We have no single blueprint for collaboration – we want to encourage it to grow organically over time. Examples such as the Interdisciplinary Research Centre in Polymer Science Technology; the Genetic Innovation Network; the Materials Centre South West; and the Biomaterials and Tissue Centre for Industrial Collaboration show the range of possibilities that already exist. We have invited HEFCE, in consultation with the Office for Science and Technology, to provide funding to incentivise the formation of productive collaborations. We have also set up a sector-wide Research Forum which will consider this issue. Costs and Benefits 8. The immediate costs of additional support to the very best departments have been borne by those other departments who might otherwise have received funding – notably those with ratings of 4 and below. HEFCE has decided no longer to fund departments rated below 4 and to transfer £20 million (2% of HEFCE’ overall research funding) to 5 and 5* departments. s 9. The money available for departments rated 4 (£118 million) will remain constant in real terms in 2005/06 This commitment will provide institutions with a level of certainty to plan strategically and determine for themselves how best to direct their research funding to departments which have potential to improve. 10. The immediate benefits of these proposals will fall to those highly rated HEIs which benefit from extra funding. Ten institutions will gain 77% of the additional funding to reward excellence. 96 institutions will receive over £5 million. The wider benefits should accrue to the overall quality of research in HEIs. Greater collaboration will enhance dissemination, and generate economies of scale and scope in the case of inter-disciplinary research. Rewarding research excellence should improve the level of world class research in the country, and support leading edge innovation, making our research more internationally competitive. 11. The costs of support for collaboration will be borne by HEFCE, using
an additional £37 million in their Strategic Development Fund over the next three years. This use of an existing programme, linked to institutions’ mainstream planning, should mean minimal additional administrative burdens for the sector. Wider Considerations 12. The realignment in research funding, over time, may lead some HEIs to re-evaluate their core mission. Since HEIs are important contributors to their local economies, any changes could have an impact on their regions. It is likely that the outcome will result in some regional concentration. While 56% of HEFCE research funding currently goes to 3 regions in the south east, there is still considerable funding to other regions and there are 5* departments in every region. However the outcome of the 2001 RAE has not resulted in a significant shift in the geographical distribution of research funding. 13. Any large-scale change in the pattern of research capacity in HEIs will affect employers nationally. However, we consider that any such change is likely to be slow, with ample time for reflection along the way. Institutions may wish to take greater advantage of the increased money in the Higher Education Innovation Fund, which will support Knowledge Transfer activities and may be particularly valuable to less research-intensive institutions. We will support emerging and improving research and make sure that the system does not ossify Objectives and Options 14. The objective is to ensure that the allocation of funding overall encourages and rewards promising departments with comparatively low research ratings, particularly for work in emerging and strategically important research areas. 15. HEFCE consulted on how institutions themselves can identify which of their 4 rated departments have the potential to improve in quality, and focus funding on developing these areas. The White Paper originally proposed a special peer review exercise (‘ mini RAE’ for managing this, but early ) feedback revealed that this was seen as unnecessarily costly, burdensome on institutions, and hard to organise. 16. Additionally, HEFCE have identified 7 subject areas where the quality of research is less established, for ‘ capability funding’ This will be allocated . to departments who achieve 3a or 3b in nursing; other studies and professions allied to medicine; social work; art and design; communication; cultural and media studies; dance, drama and performing arts and sportsrelated studies. 17. Following extensive consultation on Sir Gareth Roberts’review of research assessment last year, the UK funding bodies announced in February
this year, the framework and timing of the next RAE in 2008. The restyled RAE, based on the majority views from the sector, introduces several features which will support and encourage a dynamic and improving research base. For example, the introduction of quality profiles in place of a single grade assessment should provide greater opportunities for researchers and departments to evaluate the quality of their research. The funding bodies have also consulted on the panel configuration and recruitment and invited views on ways to encourage representatives qualified to assess quality in interdisciplinary and business related research. Costs and Benefits 18. This is part of the overall Government strategy to concentrate research funding on the best performing departments, and similar costs and benefits apply. Some institutions, and some departments, will gain; others will lose; and overall the Government believes that there will be more focussed and high quality, internationally competitive research in our universities. 19. The HEFCE consultation proposes that the sector uses its normal strategic and management planning process to analyse and determine those areas/departments in each HEI where research has the potential to reach world class quality. There would therefore be minimal external administrative burden. 20. The additional capability funding of £20 million will benefit departments with research in these areas. This capability funding will continue until the next RAE. Wider Considerations 21. As for the previous proposal.
We will invest in developing and rewarding talented researchers. There will be rigorous new standards for government-funded research postgraduate places, and good researchers will be rewarded, through the extra investment in research in general, money earmarked for pay, and more time to concentrate on research. Objectives and Options 22. The broad objective is to improve the quality and supply of talented HEI researchers, particularly postgraduate research students. 23. One element of this was to ask HEFCE to set high minimum standards for the training of research students, which must be met before HEIs can draw down funding for research degree places. This follows a review of UK research degree programmes set up by the four UK funding bodies and overseen by a steering group chaired by Professor Roland Levinsky (‘ Improving standards in postgraduate research degree programmes’October 2002). The review recommended such a set of minimum standards, having found great variability in the quality of research degree provision across the
UK, despite the introduction in the late 1990s of the Quality Assurance Agency’ (QAA) Code of Practice on postgraduate research degrees. s 24. A second element is more incentives to attract and retain talented researchers and improve the career opportunities for researchers. Both Sir Gareth Roberts’review of the supply of people with skills in science, engineering, technology and mathematics (SET for success), and the House of Commons Science and Technology Committee, have highlighted the fact that, in spite of a relatively improved position in 2000-2001, recruitment of research students to these disciplinary areas is below the levels demanded by industry and academia. There is an urgent need to do more to offer junior researchers attractive careers paths. 25. OST are taking forward four particular measures here. Firstly, an increase in the minimum Research Council PhD stipend to £12,000 by 20052006, with the average increase in excess of £13,000 in areas of recruitment difficulties. Secondly, an increase in the average Research Council postdoctoral salary by approximately £4,000 by 2005-2006. Third, the provision of two weeks transferable training at the end of students’PhD training, to enhance their employment and career opportunities. Fourth, 1000 new Academic Fellowships to be created over five years from 20042005. Following consultation by OST the new Academic Fellowships scheme was launched during Science Week in March. The scheme, open to all HEIs, will be managed by the Research Councils and will guarantee a permanent contract following the 5-year Fellowships, thus providing contract research staff with stable career paths. 26. Following consultation on the Promising Researcher Fellowship scheme, HEFCE will mainstream resources to support talented researchers in non-research intensive departments within the new Rewarding and Developing Staff initiative as part of institutions’Human Resources strategies. 62 institutions will benefit from the allocation of £5 million. Costs and Benefits 27. There is some cost to the sector of the new minimum standards for research student training associated with the financial cost of delivering the provision underpinning the standards, and the increased level of accountability. 28. These new standards are being introduced alongside a new funding methodology for supporting the training of research students. At present, the unit of funding varies according to RAE ratings. HEFCE has consulted on a proposal to develop a unit of funding per student that corresponds with the true cost of delivering high quality supervision in different subject areas – regardless of RAE rating. The effect of this will be that institutions which meet the new minimum standards, but have relatively lower RAE ratings, will tend to benefit, relative to institutions with higher RAE ratings which also meet the standards. Costs will also fall on institutions which do not already comply with the standards proposed (a clear minority across the sector).
29. The funding bodies propose to incorporate the monitoring of threshold standards into the Quality Assurance Agency (QAA) institutional audit. This will synchronise it with the assessment of teaching and focus largely on an assessment of institutional quality assurance procedures, rather than the more onerous method of monitoring the provision itself. The funding bodies have been working with QAA and the Research Councils, which also prescribe minimum standards for the research doctorate programmes that they support, to identify areas where standards or monitoring could be coordinated and embedded within the QAA code of practice. The funding bodies remain committed to announcing minimum standards for research degree programmes by the summer of 2004, prior to their implementation in 2005-06. 30. The benefits of the proposal for minimum standards flow first to the students themselves – more transparent and robust arrangements for supervision, progression, examination and feedback which will help to mitigate the risk of failing to complete a high quality research project. This also benefits institutions. And improving the consistency and quality of PhDs will raise regard for academia in general, and increase the skill set within the national economy. 31. The costs of rewarding researchers fall on the public purse, via HEFCE and the Office for Science and Technology (OST). OST total commitment for increased financial support and new training programmes from 2005-2006 is £97.30 million. This comprises: increases in postgraduate research stipends £35.46 million; increase in post doctoral salaries £32.46 million; New Academic Fellowships £12.46 million; and transferable skills training for PhD students £16.92 million. For the Promising Researchers Fellowship, the total cost to HEFCE will be £5 million per annum. 32. The benefits will be assisting HEIs and Research Councils to recruit and retain more high quality researchers, improving the performance of research across the sector. Wider Considerations 33. As with other proposals above, improvements in the quality and standing of research in UK universities will help all sectors of industry, and the national economy. We will create a UK wide Arts and Humanities Research Council, to put the organisation of funding for the arts and humanities on the same footing as funding for science and technology Objectives and Options 34. The policy objective is to change the existing Arts and Humanities Research Board (AHRB) into a Research Council with different objectives but equivalent legal status to the existing Office of Science and Technology (OST) funded Research Councils. This will be the first new UK Research Council created since 1993 and will bring funding for research in the arts and
humanities alongside the sciences for the first time, under the OST. Additionally, it offers the best prospects of furthering research in this area and permitting such research to play its fullest role in enhancing national life. 35. The background and rationale for this proposal, including other options, were considered by a review of arts and humanities research funding, commissioned by the Government and the devolved administrations, which reported in July 2002. Costs and Benefits 36. There will be some implementation costs for the AHRB in moving to the mechanisms used by the Research Councils. These additional costs will be borne by the DfES and the devolved administrations through the existing funding of the AHRB by the funding councils. 37. The benefits of the proposal should include stronger links between researchers in different disciplines; further collaboration between arts and humanities and the sciences; imaginative inter disciplinary research: more participation by the arts and humanities in national and international programmes; and reduced bureaucracy for institutions as AHRB systems are aligned with those of the other research councils. But more importantly, it will improve the effectiveness and sustainability of the AHRB and there will be better accountability and governance as the AHRC, like the other Research Councils, will operate as a non-departmental public body. Wider Considerations 38. None.
CHAPTER 3 – HIGHER EDUCATION AND BUSINESS
Stronger partnerships will be encouraged between HE institutions in each region and the Regional Development Agencies (RDAs) and other agencies charged with promoting economic development. This will include RDAs being given a stronger role in steering the Higher Education Innovation Fund (HEIF) Objectives and Options 1. The immediate objective is to ensure an appropriate focus of the Higher Education Innovation Fund (HEIF) round 2 proposals on regional development priorities. HEIF is now a permanent third stream of funding for higher education institutions alongside funds for teaching and research, and HEIs should accordingly be closely linked with the emerging agendas of RDAs. The bidding process, which involved RDAs throughout, is now complete and awards have been announced. 2. The broader goal is to strengthen HE-RDA partnerships more generally, for example by encouraging: * * * An enhanced role for the RDAs in matching supply and demand for higher education; Involving RDAs further in the Aim higher campaign (see chapter 6), to help address regional needs for access to higher education; Asking RDAs to take responsibility for galvanising the business community to work harder to make best use of the opportunities offered by higher education, particularly helping small and medium enterprises to articulate their needs.
Costs and Benefits 3. This proposal does not place any additional burden above that applying to the first round of HEIF in 2001. All HEIs were invited to bid for HEIF funding, but this was entirely optional. RDAs were encouraged to contribute to additional or complementary activities and to work with HEIs to assemble wider funding packages. RDAs were proactively involved in the HEIF2 bidding process, and were fully represented on one of the four assessment panels. RDAs were also part of the Advisory Board that recommended which projects should receive funding. 4. The benefits of the HEIF second round bidding process was that proposals were better fitted to local needs, because of the RDA input. This should enable better matching of demand and supply in skills, and enhance economic growth. 5. More generally, the benefits of improved HEI-RDA partnerships will be to increase higher education’ contribution to regional development. s
6. A total of 124 awards for HEIF2 have now been announced, worth 187 million over the next two years (academic years 2004 – 06), the DfES share of this is 56 million and the OST share 131 million. Wider Considerations 7. This activity with RDAs should contribute to the development of Regional Economic Strategies, and the Frameworks for Regional Employment and Skills Action. The Learning and Skills Council will also have an interest here. There will be funding within the total HEIF programme to set up a network of around 20 Knowledge Exchanges to promote the critical role of less research intensive HE institutions in transferring technologies and knowledge, and in skills development, within local communities of practice Objectives and Options 8. The objective behind introducing Knowledge Exchanges is to strengthen the development of knowledge transfer activity in less researchintensive departments/groups, with the aim of increasing the responsiveness of HE to business needs for skills development. Proposals were invited from individual institutions, or institutions working in consortia - either with other HEIs or local FE colleges. To secure funding a KE needed to demonstrate: excellent work in, or proposals for, both knowledge transfer and skill development, with relationships with employers and businesses in both the public and private sectors; * that the funding will lead to substantial improvement in what the institution or consortium can achieve; * strong support from employers and good partnerships with key stakeholders, including the relevant RDA, and Sector Skills Councils, and a demonstration of how its work fits into the RDA strategy and helps serve the local and regional economy; * a capacity and willingness to work with other universities and colleges to spread good practice and help improve their performance. 9. This proposal is supported by evidence from the UK Community Innovation Survey, conducted by DTI in 2001, which estimated that only 16% of UK businesses use information from the HE sector to help with innovation. Costs and Benefits 10. Direct costs of £16 million will fall to DfES. Some bidding costs will fall to HEIs, but the bureaucracy has been minimised by mainstreaming the knowledge exchange activity within the HEIF2 process. Applications for funds were submitted to HEFCE by 25 February and the assessment process was completed in May. Awards have now been announced and HEIs will have clear access to funds from August 2004. *
11. Benefits will flow to each approved centre of knowledge exchange activity, who will receive up to £500,000 funding over five years, plus the chance to build up their expertise in the important and growing area of knowledge transfer. Increasing and developing knowledge transfer activities will maximise the intellectual capital generated by HEIs and develop research opportunities for businesses. These activities will enhance economic growth. Wider Considerations 12. Knowledge Exchanges will form part of a wider network with the New Technology Institutes announced in the Government’ 2001 white Paper on s enterprise, skills and innovation. They will also be well placed to pick up any recommendations from the Lambert and Innovation reviews. The new sector skills councils will develop stronger alliances between business in their sectors and the relevant departments in higher education institutions, both to develop and market courses and involve employers in the delivery of learning Objectives and Options 13. The objective of this proposal is to ensure that the higher education sector has up to date knowledge of employer needs in vocational areas, and to help engage employers with institutions on curriculum development, placements for students in industry, and exchange of staff. At present we believe there is considerable potential for improvements in all these areas, but the task is only just starting. Costs and benefits 14. This is a long-term agenda, because the sector skills council network is still being established; the full range of councils is not due to be established until the end of May 2004. In the short term, costs and benefits will fall on, and to, individual HEIs and Sector Skills Councils as they establish their working relationships. Wider Considerations 15. Much of this agenda is equally relevant outside England, and we will work with the devolved administrations in ensuring that the Sector Skills Development Agency and sector skills councils are able to work directly with the new unified teaching quality enhancement body (see Chapter 4).
CHAPTER 4 - TEACHING AND LEARNING
Student choice will increasingly work to drive up quality, supported by much better information. The results of a national survey of student views and a wide range of information about teaching standards including the judgements of external examiners - will be published. An easy-to-use guide to HE, overseen by the National Union of Students, will help students make choices. Objectives and Options 16. The broad objective is to help students become intelligent customers of an increasingly diverse HE provision. There are three particular proposals here. * Undertake a national survey of students’views on their learning experience, with the results to be published to inform the choices of prospective students. Publish external examiner judgements about the quality of HEI courses and the standards of students’work. Ask the National Union of Students to produce a new guide to help potential HE students make more relevant and better informed decisions about courses of study and institutions.
* *
17. The first two approaches were agreed by the key stakeholder organisations in HE prior to the White Paper (part of the Cooke Group reforms). Costs and Benefits * HEFCE are piloting the survey at present to assess possible costs. They plan to administer it through a centrally commissioned agency, and are advising institutions to notify their students that they may pass on their contact details for this purpose. This will involve minimal or no burden for HEIs. For publishing external examiner reports, a pilot has already been run, which reported that the costs of the model originally proposed could be in the region of £5-£8 million a year to the sector. A revised, and much simpler approach, removing the requirement for external examiners to produce special summaries of their reports, will now be implemented. The DfES will meet the cost of publishing and distributing the NUS guide to students, at a cost of around £120k for preparation/publication.
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18. The benefits of all these proposals flow mainly to students, in the form of better information to help them choose the right institutions and the right courses for them. Institutions are also likely to find long-term benefits from increased transparency and clearer pictures of customer views.
Wider Considerations 19. None.
We will legislate for the establishment of an independent adjudicator for student complaints in the forthcoming higher education bill, but have asked the sector to press ahead with establishing a voluntary independent adjudicator in the meantime Objectives and Options 20. The objective of this proposal is that higher education students should have access to a fair, open and transparent means of redress in circumstances where their complaints against HE institutions cannot be resolved by institutions’internal procedures. 21. The current arrangements for unresolved complaints by higher education students are unsatisfactory. In a number of HE institutions, students’final appeal is to a Visitor and the right to access the Courts can be limited. In other institutions, the final external appeal is to the Courts, which can be timely and costly for the student. 22. Consultation with the sector before the White Paper revealed substantial support from HEIs for an independent adjudicator to hear student complaints, and recognition that ultimately legislation would be needed to underpin whatever arrangements were put in place. The Government proposes to approve an independent reviewer of unresolved student complaints and require institutions to subscribe to it. 23. It is also intended to limit the jurisdiction of the Visitor over these complaints. The DfES expect the Office of the Independent Adjudicator for Higher Education, which has been established by the sector on a voluntary basis, to be the independent reviewer approved by the Government. 24. An alternative option for achieving these aims would have been simply to limit the jurisdiction of the Visitor thus allowing all students who had unresolved complaints against their institutions to use current legal remedies available through Courts. We rejected this because an independent system of review, external to the institution, looked to offer students and institutions a cheaper and less formal means of settling complaints. 25. Students taking their complaints to the independent reviewer will be able to ‘ stay’Court proceedings for six months. This time-limit will be extended to eight months for students wishing to initiate Court proceedings under the Sex Discrimination, Race Relations and Disability Discrimination Acts. 26. It is also intended that the Visitor’ jurisdiction over staff complaints will s be limited further so that all disputes related to employment, which could be
brought before a Court or Tribunal, cannot be taken to the Visitor. Costs and Benefits 27. The costs of the establishment of the Office of the Independent Adjudicator are likely to be in the region of £500,000 with similar annual running costs. The burden of these costs, in advance of legislation, will fall on Government with higher education institutions meeting the costs once they are required to subscribe statutorily. We expect that institutions’subscription fees will vary according to the size of the institution. Fees may range from around £2,000 to £10,000. 28. There are potentially significant financial benefits. Firstly, removing the jurisdiction of the Visitor over student complaints will save costs to Visitors which in turn may save costs to institutions. Where Visitors currently employ legal advisors (usually QCs), costs can be between £1,000 to £5,000 per case, depending on the amount of work involved. It has been estimated that complaints taken to the Office of the Independent Adjudicator will cost around £1,500 per complaint although we would expect these to be reduced over time. Therefore savings in Visitors’costs may be more than the cost of the Office considering the complaint. 29. Secondly, if the Office’ involvement leads to a reduction in the volume s of disputes reaching the Courts, there will be further savings. Depending on the complexity of the case and degree of representation involved, institutions generally expect to pay between £2,000-8,000 for legal representation in a County or High Court case, although costs can run into tens of thousands of pounds in some cases. 30. Further benefits will fall to students and institutions, who should gain a more effective and straightforward means of resolving disputes than is currently available. A wider benefit to the institution will be the establishment of a body of judgements from the Office which will inform institutions on weaknesses in their internal complaints procedures and will assist them in resolving student complaints without recourse to external bodies. 31. There are few complaints from staff which are currently considered by Visitors which could be considered by the Courts or Tribunals. Any savings in Visitor costs will be matched by an increase in Court or Tribunal costs. Wider considerations 32. With all improvements in redress procedures, there is always a risk that the volumes of complaints that cannot be resolved internal to an institution could increase. We believe that the sector can minimise this risk through following good practice on handling student complaints. New national professional standards for teaching in higher education will be established as the basis of accredited training for all staff, and all new teaching staff will receive accredited training by 2006
Objectives and Options 33. The overall objectives are to ensure that students in HE receive high quality teaching, and generally to raise the profile of learning and teaching and the status of teaching as a profession. This specific measure is intended to establish consistent expectations of teachers in HE, and to ensure that all teaching staff coming into the profession are trained to enable them to perform their role well. There are currently no nationally agreed professional standards, and no obligation on institutions to train incoming teachers. 34. Whilst the general evidence is that HE teaching quality is good (evidenced for example by subject review outcomes), best practice in education has increasingly recognised that explicit standards are a crucial element in securing consistency. We believe teaching in higher education should be treated as a profession in its own right. 35. An alternative option was considered – to legislate for all HE teachers to have a specified teaching qualification, following practice in FE. This was rejected as being a disproportionate response. Instead, we decided to invite the sector to develop standards through the new HE Academy, ensuring that the new work builds upon current best practice. Costs and Benefits Standards 36. The development of standards will build upon existing work and capacity in the Institute for Learning and Teaching in Higher Education, working with partners like the Staff and Educational Development Association. The intention is to look at best practice in existing criteria for accreditation and training, and to consult widely on proposals in 2004. The costs of developing the standards will be met through the funding of the new HE Academy. Training 37. The vast majority of institutions already provide training for new staff leading to a qualification accredited by the ILTHE, and the extent of additional costs will be variable. HEFCE will provide some funding to support institutions’ development work in this area. The principles of flexibility and proportionality will be observed in the development of the training framework, and HEFCE will consult widely before implementing proposals. 38. Mutual recognition will be pursued as far as possible - i.e. recognition of existing qualifications which meet the standard, so that staff do not need to re-train. The scheme will treat different classes of staff appropriately (for example, there will be much lighter expectations about training and qualifications for visiting professional lecturers from those for full-time lecturing staff). Monitoring will be conducted through existing staff record systems, which will need only a minor addition.
39. Setting national standards which underpin staff training should increase the professional profile and effectiveness of teaching in HE and thus benefit both staff and students. Wider considerations 40. None.
The external examining system will be strengthened by improved training and induction, including a national programme for external examiners by 2004-05
Objectives and Options 41. These measures are intended to ensure that external examiners are consistently and adequately equipped with the skills and information they need to fulfil their critical role in maintaining academic standards. The UUK/SCOP/QAA round-table discussion meetings on external examining held in 2002 demonstrated that there is a great diversity of practice across institutions and scope for strengthening the system. The measures align with the recommendations from the sector’ Teaching Quality Enhancement s Committee (chaired by Sir Ron Cooke) which was remitted to consider how to strengthen external examiner training. The Committee’ recommendations s were accepted by the sector bodies who are now taking action to implement them. 42. The proposals on institutional training are intended to build upon the best current practice, so no other options were considered. The possibility of making the new national development programme obligatory - rather than as an additional resource for examiners - was considered, but rejected as being a disproportionate and overly burdensome approach. Costs and Benefits HEIs’internal training 43. HEIs will bear the costs of strengthening their development programmes for internal examiners, and induction programmes for external examiners. The costs will vary depending upon the strength of current arrangements: additional funding will be made available for staff training and CPD, which will contribute towards some of the cost. The level of funding will be agreed nearer implementation, as a greater understanding of the range of costs to institutions is developed. National programme 44. The national programme will be taken forward through the HE Academy (see below), linked with the new staff training programme. The costs in the Academy will be met through the combination of funding bodies and institutional subscriptions.
45. The benefits of these measures will be improved support for examiners, enabling them to fulfil their role better, and strengthening of the assurance of standards in HE. Wider Considerations 46. The External Examiner system is under considerable pressure, and training should be directed to assisting effectiveness. Incorporation into more general new staff training and CPD (linked with existing accreditation and training schemes) should help. To underpin reform, we will support improvements in teaching quality in all institutions. Additional money for pay will be conditional on higher education institutions having human resource strategies that explicitly value teaching and reward and promote good teachers Objectives and Options 47. The objectives of this proposal are to continue to support the significant progress already made within HEIs to modernise their human resource strategies, and to provide more money explicitly to recognise good teaching. 48. Specifically, DfES will provide an additional £50 million in 2004-05 and £117 million in 2005-06 to HEIs who can demonstrate that it will be spent on rewards for the best teaching staff. In addition, the £170 million funding that HEFCE are providing to support institutions’HR strategies in 2003-04 will be consolidated into the block teaching grant from 2004-05. Hence there is both new money, and more flexibility in how existing money is spent. Both of these build on the Rewarding and Developing Staff initiative (RDS), that HEIs have implemented since 2001. 49. There is evidence to show that human resource systems have traditionally rewarded high quality researchers rather than high quality teachers . For example, a questionnaire survey of promotion practices in the UK in 1994 demonstrated that only 12% of promotion decisions were made primarily on the basis of teaching excellence; and more recently, HEFCE’ s 2001 analysis of institutional HR strategies ‘ not reveal significant evidence did of reward mechanisms for excellent teaching’(National Coordination Team ‘ Recognising and Rewarding Excellent Teaching’2002). Costs and Benefits 50. The £50 million and £117 million new money will be a cost to Government. It will be in a ring-fenced fund, and there will be additional work for HEIs to produce action plans on how to spend it, and for HEFCE to analyse them. However, both these costs should be relatively low. All institutions now have HR strategies, thanks to the RDS work already undertaken, giving them a sound basis for making proposals on rewarding the best teachers. The HEFCE costs should be low as they will build on analysis already undertaken and will be mitigated by the fact that HEIs would need to
prepare budgets to control expenditure anyway. 51. The consolidation of the existing funding should not impose any extra costs beyond minor changes to HEI internal accounting processes. 52. The benefits of the extra funding will be felt by those excellent teaching staff at HEIs who receive the funding. HEIs in general should benefit from any improvements in the perceived rewards for teaching in the HE sector. HEIs will also benefit from the consolidation of the £170 million into the teaching grant; this will give greater flexibility to institutions to decide on the best use of the money. Wider Considerations 53. None.
We will also celebrate and reward teaching excellence. We are consulting on the establishment of a single national body – a teaching quality academy – which could be established by 2004 to develop and promote best practice in teaching. Objectives and Options 54. The objective is to establish a high profile national professional organisation for teaching in HE, supporting and developing the best practice in teaching and learning. 55. The aim is that the new Academy – which will be fully operational in Summer 2004 and officially launched in Autumn 2004 - will have a strategic role with respect to policies designed to enhance the student experience and will be directly concerned with curriculum and pedagogic development in HE. Simultaneously we hope to reduce the confusion and overlap created by the co-existence of a number of bodies all concerned with ‘ quality enhancement’ (Institute for Learning and Teaching in Higher Education (ILTHE), Learning and Teaching Support Network (LTSN), Higher Education Staff Development Association (HESDA)). 56. The sector’ Teaching Quality Enhancement Committee (TQEC) s considered a range of organisational models including separate agencies and combinations of two. It concluded that there were significant overlaps in the three agencies and a new body would be the most cost-effective arrangement (also recommending that consideration be given to closer working with the proposed Leadership Foundation). 57. LTSN and ILTHE have transferred into the Academy from May 2004. The HEFCE National Co-ordination Team has also been incorporated into the new body. HESDA staff have transferred to the Leadership Foundation, and discussions are continuing on how HESDA's current activities might be appropriately housed in the Academy.
Costs and Benefits 58. HEFCE has agreed to provide an initial £3.4 m for the transitional period up to December 2004, to support the establishment of the Academy, in advance of final business plans being submitted in the Autumn once the new Chief Executive of the Academy is in post (August 2004). 59. The TQEC final report outlined an indicative budget for the Academy to show that it would be financially feasible. Its total annual income was estimated at approximately £14m, made up by £2,950k Institutional Subscriptions, £850k Individual Membership Fees, £9,000k Funding Council programmes funding, £1,500k Contract and earned income. It is expected that the implementation of the HE Academy will provide considerable benefit for the HE sector for minimal increase in burden. The HE sector should get better and more efficient use of Academy services because the Academy will provide a ‘ one-stop shop’for all quality enhancement. For many HEIs it will replace multiple subscriptions (ILTHE and HESDA) by a single subscription 60. The TQEC final report outlines an indicative budget for the Academy to show that it would be financially feasible. Its total annual income was estimated at approximately £14m, made up by £2,950k Institutional Subscriptions, £850k Individual Membership Fees, £9,000k Funding Council programmes funding, £1,500k Contract and earned income. The subscription costs for HEIs are likely to be mandatory for the first three years, but there may be offset savings to HEIs in that a single subscription will replace multiple subscriptions . In addition, the work of the Academy should be more cost effective in taking forward development work through one body, rather than several. 61. The benefits of a unitary body for quality enhancement are detailed in the final report of the TQEC. These should include: * For institutions: an enhanced and much more closely defined level of services from a more strategic and comprehensive support agency with a clearer remit and accountability. Free access to mainstream teaching material and advice will be available to all relevant academic staff; For individuals: ILTHE members, and others who qualified, would obtain professional membership and become fellows of a more influential body, able to develop professional standards and CPD functions, at a lower annual fee; Discipline groups: would continue within an enhanced framework able to provide greater research and foresight support and to connect their activity better to the needs of individuals and institutions; Staff, students, employers and other stakeholders: would have explicit access to a broader range of support, and also to inform policy and direction;
*
*
*
*
Funding bodies: would see the sector giving greater strategic priority to professional development in teaching and learning, and would have better opportunities for delegating initiatives to a larger, more businesslike agency, with clearer management accountability.
Wider Considerations 62. The relationship between the new Academy, the Learning Foundation, the Centre for Excellence in Leadership, and the proposed Lifelong Learning Sector Skills Council (which are all new and emerging organisations) will need to be carefully articulated - to ensure that there is clarity about their respective remits and appropriate mechanisms for communication and collaboration between the bodies. The National Teaching Fellowships Scheme will be increased in size to offer substantial rewards to twice as many outstanding teachers as at present Objectives and Options 63. The objective is to provide more rewards and role models for excellent individual teaching. It was decided to build upon the well established scheme already in place. Costs and Benefits 64. There are no direct costs to HEIs. The scheme was reviewed to ensure that the method for application imposed least burden on HEIs and the Academy will implement it taking account of burden. 65. Expanding the scheme will raise the costs to HEFCE from £1 million per annum to £2.5 million per annum over the next three years plus additional administrative costs. 66. The scheme will benefit individual practitioners whose practice is celebrated, as well as providing opportunities for pedagogic work to increase understanding of effective practice Wider Considerations 67. The Fellows and their projects will contribute to the communities of practice and evidence base in the new Academy. Centres for Excellence in Teaching and Learningwill be established to reward good teaching at departmental level and to promote best practice, with each Centre getting between £200,000 - £500,000 a year for five years, and the chance to bid for capital funding Objectives and Options 68. The objective is to encourage, identify and publicise excellent teaching at team level within HEIs, and reward it with funding. The rationale, as
identified in several other proposals in this chapter, is that teaching in HEIs is at present under-valued, to the detriment of academic staff, institutions, students and overall national skill levels. 69. The alternative of putting additional funding into the teaching grant was rejected because this would only have a marginal effect without providing targeted rewards. 70. There is a two stage bidding process to become a Centre for Excellence in Learning and Teaching (CETLs). HEFCE has recently announced the outcomes of stage 1 (June 2004).. Costs and Benefits 71. As a ring fenced fund for bidding against, there would be additional administrative work for HEIs who chose to bid, though of course there would be no obligation to do so. Questions of the burden that this would present, and how to minimise it, were put to the sector in a HEFCE consultation document, and will be addressed in HEFCE’ further development of the s initiative. HEFCE is proposing to help with costs incurred in the second stage of bidding, using information from institutions to establish average costs. 72. A successful bid will have considerable benefits for an institution, both in terms of reputation (being recognised for teaching excellence by peers) and funding. Anything which raises the status and standard of teaching in the HE sector will have wider benefits to the sector and the nation. Wider Considerations 73. Centres will have sector wide impact on enhancement of the student learning experience, and collaborative activity with the HE Academy will be important. The Centres will also work closely with the subject centres in the Academy. To recognise excellent teaching as a university mission in its own right, University title will be made dependent on teaching degree awarding powers – from 2004-05 it will no longer be necessary to have research degree awarding powers to become a university Objectives and Options 74. The Government’ objectives are to have a diverse higher education s sector where institutions focus on their individual areas of strength. Within this, we want to make clear that teaching is a distinct and valued mission for universities, on its own as well as in conjunction with research. 75. The current framework does not allow institutions to be awarded university title on the basis of the quality of teaching nor if they specialise in a few particular subject areas. 76. This framework hinders achievement of our objectives and risks future
development of the sector. Institutions offering high quality teaching should be eligible for ‘ university’title. In addition, the current criteria for institutions to be granted the power to award degrees fails to reflect innovations in the sector. 77. Modernising the current framework for awarding university title and degree awarding powers is the simplest option for achieving the Government’ objectives. Possible other options, such as removing or s significantly relaxing controls over the use of university title or the power to award degrees could significantly damage the reputation and quality of the sector. 78. The QAA has been asked to propose how the criteria might be amended to implement this policy. The Government is consulting widely on the revised criteria. Costs and Benefits 79. The direct costs of this proposal are very small, being costs to the Department associated with the consultation. The new criteria would not change the cost and time required for institutions in applying for university title and degree awarding powers. QAA has been asked separately to consider how its processes for considering applications might be further streamlined and made more transparent 80. There will be significant benefits to high quality teaching and specialist institutions that are currently barred from applying for university title. Should they meet the new criteria and secure university title, the standing of the institution will increase and it may be more attractive to potential students, increasing income to the institution. Students will benefit from a wider choice of institutions awarding degrees. Wider Considerations 81. The revised criteria would apply in England and Wales. The Scottish Executive proposes to continue to use the current (1999) criteria in Scotland, but is keeping the situation under review.
CHAPTER 5 – EXPANDING HIGHER EDUCATION
We will expand foundation degrees, making them the main workfocused higher education qualification Objectives and Options 1. The policy objective of this proposal is to offer a high quality, workfocused qualification, which will contribute to the reduction in skill shortages at the associate professional/higher technician level, and provide flexible and accessible progression routes. The goal is to make Foundation Degrees (FDs) the standard intermediate level HE qualification. 2. The proposals take forward an existing Government commitment to the development of FDs. David Blunkett launched a consultation in February 2000, proposing the introduction of pilot FDs in 2001. The rationale was intermediate skills shortages and the need to diversify and expand higher education towards employability skills. There were lessons to be learned from popular two-year HE programmes in other parts of the world - such as the American Associate Degree. In spring/summer 2000 the National Skills Task Force commended the introduction of FDs as strengthening the work based route to HE. 3. This policy will lead to a gradual replacement of HNDs with FDs. HNDs, although having support from some employers in some sectors, have been declining (down from 80,000 to 60,000 in the last 2-3 years). The development of FDs, by employers working with higher and further education institutions, Sector Skills Councils and Regional Development Agencies, will ensure that courses are designed to meet skill needs at national, regional and local level. In previous forecasts, 80% of the expected 2.1 million additional jobs to 2010 were in occupations where the majority of graduates are employed. The latest evidence is even more positive. Of the 13.5 million total jobs expected to be filled by 2012, 50% - that’ 6.8 million - are in occupations s most likely to demand graduates. 4. This close link with employers particularly distinguishes FDs from HNDs. Furthermore, as university awards quality assured by the QAA (rather than QCA/Edexcel awards), they are subject to design criteria, set out in QAA draft benchmarks, which has not been the case for HNDs. FDs thus bring greater coherence to intermediate level HE awards. 5. A number of employers are already using FDs. For example in the private sector, BMW and KLM have used them to deal with specific skill shortages. In the public sector FDs are also addressing skill needs in for example the National Health Service and the Police. These opportunities are proving popular with students. Numbers rose from 12,000 in the academic year 2002/03 to over 24,000 at the start of 2003/04 – just under half of them studying part time. Interviews with students show they welcome the flexibility
FDs can offer, including opportunities to learn while you earn. 6. There are plans to expand the number of FD places on offer from 2004. HEFCE have run a bidding exercise to allocate 10,000 additional fulltime equivalent places over the two years 2004/05 and 2005/06. To support this expansion, development funding is being made available to support business, sector skills councils and colleges/universities. Costs and Benefits 7. Most of the costs will relate to the design and implementation of new courses. These costs will fall on higher education institutions, further education colleges, Edexcel, and also those employers, Sector Skills Councils and Regional Development Agencies that get involved in bidding for places, producing proposals for development funding, designing courses and marketing and promoting new courses. Some of these costs will be routine for HEIs and colleges, who regularly revise, devise and promote new programmes. Other costs may be additional. HEFCE estimate that bids from around 100 institutions will cost the bidders a total of between £500,000 and £1,225,000. 8. HEFCE has undertaken a review of the costs of developing and delivering FDs and concluded that where there is a genuine partnership component to FD provision the costs are slightly higher than for conventional programmes. They are have introduced a 10% premium for FDs as a temporary measure to address the additional costs incurred through liaising with employers, handling students on work placement etc. 9. The benefits from expanding FDs and making them the main workfocused higher education qualification will be to enable employers to have access to a steady supply of people that have gained skills and knowledge that they need and value . Students will benefit from better career prospects and the economy will benefit from increased productivity. 10. The policy of a gradual replacement of HNDs with Foundation Degrees will ensure that Edexcel can work with institutions to ensure that it happens taking account of employer needs and demands. 11. The financial support that is available to develop and promote FDs will help to establish the brand with employers and students. Wider Considerations 12. Unlike HNDs, which are currently national awards, Foundation Degrees will be validated by HEIs. National coherence will be supported through a number of arrangements such as Sector Skills Council FD frameworks – the development of which is being funded by DfES over the next two years (see 15 below) –and the availability of, for example, Edexcel FDs. Bidding for new FD places is a route through which regionally-based bodies, such as RDAs and LSCs, can be involved with FD developments, along with Sector Skills Councils.
We will support employers to develop more foundation degrees focusing on the skills they really need
Objectives and Options 13. This proposal complements the previous one. It aims to encourage HEIs to develop foundation degrees, with employer input as appropriate, thereby increasing the supply of graduates with the skills to meet the growing demand for higher technical /associate professional skills. 14. In order to get employers interested in the new qualification it is necessary to provide development funding to enable them to work with HEIs/FECs. We considered waiting for them to respond to institutions but felt that they needed to be encouraged to get involved. The main way we anticipated doing this was through working with Sector Skills Councils, trade bodies and professional bodies. However, we have left open the option of supporting individual companies, groups of companies or public sector organisations, subject to state aid rules. Costs and Benefits 15. Between 2003-06, of the £8m allocated to Foundation Degree Forward, around £5m is available to support Sector Skills Councils to develop sectoral frameworks for FDs; there is £2.25m available to support frameworks in the public sector and £2m for other employer-focused initiatives. The funding will support the development and promotion of FDs. It may not cover all the employer costs. 16. The benefits will be that more employers will be involved in developing FD provision and it therefore stands a better chance of meeting current and future skill needs. Employers, by getting involved, will have greater ownership of FD development and are consequently more likely to value the courses and to offer jobs to FD graduates. FD students will benefit from participating on courses that have had real employer input. We will encourage students to take FDs by offering financial incentives 17. We have reviewed the intention to offer specific incentives for some FD students in the period running up to the introduction of flexible fees, and concluded that it is more appropriate to direct the funding through the normal student support channels to allow for additional growth in the number of places offered. We will fund additional places for Foundation Degrees rather than three year honours degrees. Objectives and Options 18. The aim is to expand the number and reach a critical mass whereby Foundation Degrees are an accepted qualification of choice alongside full
honours degrees. Costs and benefits 19. Up to 10,000 additional FD places will be made available from HEFCE’ existing funding spread over the two years 2004/05 and 2005/06. s Any associated additional demands on student support budgets will be met from the £30m funding originally set aside for FD student incentives. As well as increasing the supply of people with knowledge and skills that are needed in the economy, these additional places will widen the higher education options available and increase progression possibilities for people on vocational level 3 programmes and people in work. Wider Considerations 20. The Secretary of State has told HEFCE that he expects new growth in student places up to 2005/06 to be concentrated on foundation degrees, after recognising the effect of existing commitments to growth in honours degrees. However, we do not see this as any threat to the availability of honours degree courses; numbers on first degree courses have already risen ahead of planned growth. Foundation Degrees will often be delivered in Further Education Colleges, and we will build and strengthen the links between further and higher education, to give students clearer progression pathways and support the development of work-based degrees. As part of this we will streamline the funding regimes to make collaboration easier. Objectives and Options 21. This proposal aims to ensure that Further Education Colleges (FECs) can play their full part in delivering foundation degrees. 22. First, we will consider, in limited circumstances, the direct funding of higher education in FE colleges, rather than indirect funding though an HEI. Following a review of indirect funding agreements and arrangements, HEFCE is developing proposals. 23. Second, we want to reduce the bureaucracy burden on mixed economy institutions (MEIs) who offer both FE and HE provision, and currently deal with both HEFCE and the LSC. HEFCE and the LSC have produced joint proposals for creating an integrated system covering planning, funding, monitoring, data collection audit and accountability to reduce bureaucracy for mixed economy institutions. The main points of the proposal are that mixed economy institutions will: * * Deal with a single point of contact either HEFCE for HE institutions or LSC for FE colleges Be able to access a jointly administered HEFCE – LSC fund from which mixed economy institutions could receive capital funding
(introduction 2006-07) * Submit one set of data returns for monitoring and audit.
24. HEFCE and the LSC have proposed the establishment of a longer term advisory ‘ watchdog’group with a formal brief to advise the two Councils on the burden to mixed economy institutions. A group is also being set up to assess the scope for greater alignment of review and inspection systems as they affect mixed economy institutions. 25. A practitioner sub-group will offer proposals to the Councils on the detailed work to develop an integrated funding an dplanning process for further and higher education. The group is due to report in April 2004. Costs and Benefits 26. The costs and benefits associated with these proposals will depend on the more detailed work currently being done. However, the intention is that there should be no extra costs for HEIs, FECs or business. Any increased costs will fall on the funding councils. 27. The benefits will be shared by institutions, students, the funding councils and employers. MEIs will see a reduction in administration and bureaucracy, and will be able to develop more integrated institutional plans. Students will enjoy an increase in the availability of FE and HE courses which meet local skill needs and are delivered in suitable locations. It will also be easier for them to progress from FE to HE courses and if necessary to change from FE to HE mid-year. The funding councils will be helped by the simplification of data requirements across both organisations. Employers should find a closer match between their skills needs and the available pool of FE and HE students, particularly those on ‘ vocational’HE routeways. Wider Considerations 28. Having stronger links between further and higher education will benefit students and help with widening participation. We will establish ‘ Foundation Degree Forward’ a network of , universities which are leading the development of foundation degrees, both as a catalyst for further development, a reservoir of good practice and to provide a validation brokering service for foundation degrees offered in further education, so that students can be completely confident about their quality Objectives and Options 29. This proposal aims to ensure that Further Education Colleges with a quality FD proposal have access to a service to secure a validation partner if they do not have a suitable local HE partner. FECs cannot validate and award FDs in their own right – they need a partner organisation with appropriate powers, normally an HEI. However, a local HEI might lack the
necessary expertise to validate an FEC-based FD, or might decide to be uncooperative for its own ends. There is informal evidence that some FECs have had difficulties finding HEI partners, and of HE partners withdrawing from local consortia. 30. Foundation Degree Forward will offer this validation brokering service, and will also act as a national centre for FD expertise. 31. An alternative option would be to give FECs powers to award FDs in their own right, or to create a separate dedicated FD validating Authority, removing the power from HEIs. These would both require legislation. The former may have given rise to quality assurance questions and the latter would have created an additional bureaucracy. Neither would have helped promote FE/HE partnerships. 32. Foundation Degree Forward (FDF) will also be a centre of expertise supporting FECs, HEIs and other organisations in the development of high quality Foundation Degrees, including disseminating good practice. It will also collaborate with the Sector Skills Development Agency (SSDA) and Sector Skills Councils (SSCs) in supporting the development of sector skills frameworks which will inform future curricula and delivery. 33. An option would have been not to give FDF this role in acting as a centre of expertise/disseminating good practice but to rely on institutions doing it themselves drawing on the work of the QAA and evaluation commissioned by HEFCE/DfES. However, taking into account the autonomy of universities and the need to share practice across the HE/FE divide it was felt that a new body, with representatives on its management board from the relevant sectors, should be formed. Costs and Benefits 34. The sum set aside for establishing and running FDF from 2003 and 2006 is £8m. Other costs that will fall on HEIs will be those associated with securing membership of the validation service. The application process is unlikely to require more than one person day to complete. Those HEIs agreeing to do this are likely to be able to recoup their costs through the fees they will charge for subsequent validation of FD courses. 35. There may be variation in the level of fees charged by HEIs for validation of FDs. HEFCE will be keeping a close eye on this to ensure that FECs are not charged excessive fees. 36. The benefits for FECs are that they will have access to validation of FD courses either through existing arrangements or through arrangements developed by FDF. An additional benefit to the FE sector will be establishing benchmarks for validation in terms of quality and price. There will also be benefits to HEIs of securing membership of FDF service in terms of the positive signal it sends to students and employers about the quality of their FD activity.
37. FDF’ role in providing access to expertise in the design and s implementation of FD will have benefits for students, institutions, employers and the economy. By developing FDF as a body managed through a wide range of partners, there will be greater ownership of FD developments and therefore more willingness to act on the outcome of evaluation of practice – more so than if it was driven by a Government led agency. Wider Considerations 38. None.
We will encourage flexible provision which meets the needs of an increasingly diverse student body, by improving support for those doing part-time degrees, and supporting the development of flexible “2+” arrangements, credit transfer and e-learning Objectives and Options 39. The objective is to explore how to provide learners with more flexible pathways through Higher Education, building upon established good practice. Traditional full and part-time degree models may not meet the needs of all learners either in their first or subsequent HE experience. Flexibility is therefore important to meet the needs for expansion, access and widening participation. 40. DfES and HEFCE are still considering what different options exist for taking forward this strand of work. HEFCE intends to work with institutions to set out a strategic framework for the development of flexible provision, enabling priorities to be identified and ensuring the optimum use of development funding. Costs and Benefits 41. At present this work has not reached the stage where either costs or benefits can be estimated. Any development costs will be looked at as part of the development of the strategic framework. There should be no additional costs to HEIs. Wider Considerations 42. This work will need to take account of developments in FE, to ensure a holistic view of student progression.
CHAPTER 6 – FAIR ACCESS
A unified national Aim higher programme will build better links between schools, colleges and universities, including through summer schools and a pilot programme offering students the chance to support teachers in schools and colleges Objectives and Options 43. The objective is to create a coherent national outreach programme (‘ Aim higher’ by bringing together the existing “ ) Aim higher: Excellence Challenge”and “ Partnerships for Progression” It will operate most intensively . in the most disadvantaged areas. 44. This followed feedback from HEFCE, LSC and the sector that greater integration was desirable. A Transition Task Group comprising representatives of the key Programme sponsors (DfES, HEFCE and LSC) has been set up to consider options and enable effective introduction of the unified Programme by August 2004. Costs and Benefits 45. The unified programme will pull together current DfES, HEFCE and LSC funding commitments for existing initiatives. Because it is administered regionally and sub-regionally, involving a strong level of partnership working, there may be costs to all members of the partnership in creating and maintaining it. 46. Value for money benefits will come in efficiency and effectiveness. It is not possible at this stage to quantify these benefits. Success indicators of the unified Programme will be demonstrated in terms of increased attainment, and applications to HE, particularly in target areas of disadvantage/ low participation in HE. Wider Considerations 47. The bulk of Aim higher activity and therefore funding will be at the subregional level, involving colleges, schools, universities and others. At local level it therefore interacts with a range of other initiatives aimed at schools and the school workforce, including some programmes run by the Teacher Training Agency to improve links between university students and schools. We will ensure that there are good-quality and accessible ‘ second chance’routes into higher education for those who missed out when they were younger Objectives and Options 48. The policy objective is to help widen participation in higher education (HE), by improving the contribution of access courses. There has been a
significant decline in the number of enrolments onto access courses and also a decline in the numbers going on to HE. We wish to modernise access courses so that they are sufficiently flexible and attractive to meet the needs of today’ adult learners. s 49. We are therefore asking the Quality Assurance Agency (QAA) to look at the current access course criteria and make proposals for change. Costs and Benefits 50. There will be costs to the QAA of developing the proposals, which will establish detailed costs and benefits more fully. 51. The development of a more flexible scheme could be very beneficial to learners, if it enabled a greater number and variety to progress to HE. Wider Considerations 52. None at present, pending QAA proposals.
We will work with universities to make sure admissions procedures are professional, fair and transparent, and use the widest possible range of information about students when making decisions Objectives and Options 53. The original White Paper proposals were updated in the document ‘ Widening participation in higher education’ published in Spring 2003. ’ 54. The Government is clear that admissions policies are the responsibility of the universities, not of the Government. We are also quite clear that admission to a university must be on merit, based on a student’ s achievements and potential. We also believe it would be in the interests of universities, students, parents and teachers for there to be a greater shared understanding of the options for assessing the merit of applicants to HEIs, and their achievement and potential for different types of courses. Professor Steven Schwartz, vice chancellor of Brunel University, has been asked to lead a task force to examine this issue. Professor Schwartz is supported by a Steering Group, and is due to make recommendations to the Secretary of State in May 2004 following a period of consultation with the HE sector and the wider public. 55. Other options, such as a HEFCE review and the involvement of the new Access Regulator, were put forward in the original White Paper, and have been rejected following feedback and comment. Costs and benefits 56. No costs at this stage other than the administrative support for the task force. The costs and benefits of any action will be considered in the light of
Professor Schwartz’ review. s Wider considerations 57. None at present, pending the review’ report. s
Institutions will be provided with better benchmark data on which to judge progress in widening access, and we will continue to support the work being done to secure fair access to the most prestigious universities Objectives and Options 58. The objective is to give a clearer and more realistic picture of participation in higher education by non-traditional students, by developing new performance indicators to measure it. These new indicators can then inform work to improve access by both government and institutions. Costs and Benefits 59. Costs of developing the new PIs are in an early stage of development. Some small piloting costs fall on HEIs, HEFCE and DfES. In the longer term, if new PIs are introduced, there would be compliance costs, but these should be relatively small, since current plans are to collect any new data though existing and established systems such as student support forms. 60. The benefits of developing the new performance indicators would be a clearer and more realistic picture of participation in higher education by nontraditional students. This will inform work to improve access by both government and institutions, and should ultimately benefit students from nontraditional backgrounds. Wider Considerations 61. If the new performance indicators give a different picture from current ones of how HEIs are performing in widening participation, there could be knock-on effects on any funding distribution that was linked to them. We will ask HEFCE to reform the access premium so that universities and colleges will be properly funded for the extra costs of attracting and retaining students from non-traditional backgrounds Objectives and Options 62. The objective is to widen participation in HE by students from nontraditional backgrounds, by a fairer distribution of the funds which support HEIs to attract and retain them. 63. The previous model for allocating widening participation funds, known as the “ postcode premium” has been criticised by the National Audit Office as , a relatively crude measure for identifying the students who should attract
support. The NAO was commenting on HEFCE research showing that students with lower previous educational attainment are at more risk of dropping out. 64. HEFCE consulted the sector on a revised method of allocating widening participation funding in April 2002, and respondents felt that previous educational attainment was not an effective enough measure on its own but supported a combined method using geo-demographic measures and prior educational attainment. HEFCE has therefore altered the method of funding appropriately and will consult further on measures to be used in subsequent years as better data become available. 65. The risks of not doing anything are that some institutions may bear the additional costs disproportionately and funding may not be targeted at areas of greatest need, and the possibility of higher drop-out of those students who need greater support 66. In the White paper we suggested OFFA might have a role in relation to non-completion of courses. However, on reflection, as stated in the consultation paper ‘ Widening Participation in HE’ the Government believes , that the job of promoting action to bear down on non-completion is best undertaken by HEFCE. Costs and Benefits 67. The £273 million widening participation allocation is distributed according to a formula; changing that formula produces winners and losers. If previous work has been well carried out, the new formula will be more effective in directing help to HEIs with the greatest need, and will be of more benefit in supporting students into and through their courses. Wider Considerations 68. None, beyond the general social advantages of widening participation in HE. We will appoint a Higher Education Access Regulator, who will develop a framework for Access Agreements for each institution. Only institutions making satisfactory progress on access will be able to participate in the Graduate Contribution Scheme from 2006 Objectives and Options 69. The policy objective is that access is safeguarded at those HEIs which choose to levy higher fees (see chapter 7 for more details on this). The Office for Fair Access (OFFA) is a regulatory mechanism designed to ensure this happens. 70. The original White Paper proposals were updated in the document ‘ Widening participation in higher education’ published in Spring 2003. The ’ proposal now is that institutions that wish to charge variable fees in excess of
the standard fee (currently £1,125) for any of their courses will be required to enter into an access agreement with OFFA. The agreement will set out the fees the institution wishes to charge and the courses to which they apply. Access agreements will also cover an institution’ plans for financial and other s support for students (including bursaries); outreach activity; and its own milestones for assessing progress in widening participation. 71. In allowing HEIs the freedom to charge variable fees, we will be allowing them to increase their income. As we move towards this new system, we think it right that access should be safeguarded for students from the most disadvantaged backgrounds. OFFA’ job is to ensure that this s operates in practice. Access agreements will include arrangements for outreach, financial and other support for students, and institutions’own milestones for assessing progress in widening participation. 72. Without the safeguard that OFFA represents, there is a risk that fewer students from disadvantaged backgrounds would apply to HE, and especially to institutions charging higher fees. Concern about this deterrent effect was expressed in many consultation responses to the White Paper. There is already a social class gap in participation in HE: in 2000, just 19% of young people from the three lower socio-economic groups (SEGs) were benefiting from HE compared with 50% of young people from the three higher SEGs. There are also variations in applications between types of institutions. For students who obtain A level passes corresponding to 30 UCAS points, those from the three higher social classes are significantly more likely to apply for places at Russell Group institutions than those from the lower social classes. But for those who do make an application, the acceptance rates are virtually the same – suggesting that applications, rather than admissions, are the area of greatest potential difficulty. 73. * Other options have been carefully considered. These included: Introducing variable fees with no access safeguards. This does not address the risk that higher fees may adversely affect participation in HE by disadvantaged groups. While it is impossible to predict with certainty how potential students will react, and our proposals are designed to avoid any negative effect on students from disadvantaged groups, the response to our proposals to charge variable fees have left us in no doubt that many people agree that this is a significant risk, and one that needs to be addressed. HEFCE carrying out the functions of ‘ regulator’ rather than establishing , a separate OFFA. We rejected this because of the clear distinction we see between the roles of HEFCE and of OFFA. HEFCE acts primarily as a funding body. The function we will be asking OFFA to perform is regulatory. The Government does not think that HEFCE should be asked to take on the dual role of funder and regulator in the area of widening participation. We wanted a single, clear line of responsibility for safeguarding access, to ensure transparency and public accountability.
*
*
Giving OFFA wider powers over admissions and oversight of measures to encourage retention, as proposed in the original White Paper. We rejected this because of concerns that admissions policies should remain firmly the responsibility of universities, and that HEFCE should continue to be responsible for supporting retention, as an aspect of widening participation.
Costs and Benefits 74. There will be costs in this proposal to institutions who seek access agreements, and to Government. There will be benefits to students, to institutions and to society. For institutions seeking access agreements, the costs will be in the time they spend drawing up the agreements, and their compliance costs in actually providing the bursaries and outreach work that they propose in those agreements. The former should be relatively small in terms of net additional costs, since access agreements will subsume the widening participation strategies which institutions already have to submit to HEFCE as a condition of grant. Institutions will therefore have some offsetting saving. We are exploring details of how institutions might approach access agreements, and associated costs, with a working group from the sector with representatives from UUK, SCOP, AoC and HEFCE. We hope that any monitoring of access agreements can be done using information that HEIs already provide for HEFCE, and as part of the same returns. 75. The compliance costs will vary according to the institution’ progress in s widening participation, and the needs of their students and potential students. Institutions will know OFFA’ expectations in advance, and will be able to plan s accordingly. UUK are leading a working group on bursaries, which is looking at model bursary schemes. This will be helpful to institutions and provide greater clarity to prospective students. 76. There are also implementation costs for Government in creating and staffing the Office for Fair Access. OFFA’ workload will fluctuate with peak s activity coming when access agreements come up for renewal every 5 years. We estimate the costs will average around £500,000 per year. This includes an element of costs to recognise that HEFCE will at least initially be providing staffing time and other resources to support OFFA. 77. The neediest students will benefit from bursaries and other financial support the institutions will offer them. Young people will benefit from the outreach activities that institutions will run. Institutions will benefit from being able to attract a broader cross-section of society. Society in general will benefit from the safeguarding of access to higher education at HEIs which choose to charge fees above the minimum. The extent of all these will depend on how many HEIs decide to charge fees above the minimum, and at what level.
Wider considerations 78. HEIs will want clarity about the relative responsibilities and activities of HEFCE and OFFA. DfES and HEFCE are in close and regular discussion in advance of OFFA being set up; once OFFA is set up, we expect there to be close working with HEFCE, using common data and services, and with OFFA, at least initially, being co-located with HEFCE. It will be extremely important that HEIs are not required to supply identical data separately to OFFA and HEFCE. 79. Wales and Scotland have no current plans to permit higher variable fees in the way England plans, and therefore have no plans for an OFFA mechanism.
CHAPTER 7 – FREEDOMS AND FUNDING
We will help to fund HEFCE’ and Universities UK’ proposal for a new s s Leadership Foundation to support the sector to improve leadership and management Objectives and Options 1. The objectives of this proposal, as put forward by UUK and HEFCE, are to identify and meet key leadership and management needs across the sector, and build a cadre of professional leaders and managers. In the complicated environment in which universities work, leadership and management pose exceptional challenges. Given the returns made by the HE sector to the wider economy, the Government believes it should seek to provide help where it can. 2. The sector has developed the business case for this proposal and is overseeing the setting up of the organisation. An initial needs analysis (2000) revealed the generally low level of formal management training and development, both compared with other sectors (schools and FE) and with international English-speaking HE systems. There are specific gaps in the provision on non-award-bearing training and in the quantity and range of focused research on HE leadership and management. Recent funding initiatives have suggested that institutions have now made plans to increase their spending on leadership and management development, suggesting that potential demand exists. 3. The proposal is that the Leadership Foundation should be set up as an independent company limited by guarantee which is expected to become financially self-sustaining in three years. Income would come from charging the sector for its services. 4. One variation on this basic model was considered; that there should be a single organisation for both the FE and HE sectors. However, while there are generic problems that both sectors have to face there are also substantial differences. In view of the arguments set out in the UUK/SCOP business case for the Leadership Foundation, it was agreed that the right way forward was to establish two separate organisations with their own clear missions, but collaborating in areas of mutual interest, and learning from each other and the National College of School Leadership. Costs and Benefits 5. The up-front gross cost of setting up and funding the Leadership Foundation is estimated to be around £3 million a year for the first 3 years, at which point it should widen its financial base. Most of the initial funding gap will be met by the HEFCE; the Scottish and Welsh funding councils are also both making a contribution, proportional to their population share. At around
170 institutions in the sector, all of which could potentially benefit from this venture, this is equivalent to about £18,000 of gross cost per institution per year which might otherwise have been spent on other aspects of HE. 6. Long term funding for the Leadership Foundation will come from charges to institutions using its services. It will be entirely up to the institutions whether, and how much, they use it since it will provide services in potential competition with other providers who might choose to enter the market. Apart from the pump-priming funding, establishing this organisation provides a market solution to the problem and therefore imposes no additional regulatory burden on institutions. 7. The benefits of the Leadership Foundation should include more professionalized leadership and management capacity, stronger strategic leadership for the sector and better ongoing professional development in the HE sector. Ultimately, this should help HE institutions compete more effectively for international students, and cope better with new challenges and the new freedoms to set their fee levels within the £0 to £3,000 range. All HE institutions stand to benefit in a range of ways and to a range of degrees from the services of this new organisation. The proposed scale of the foundation allows for about 700 per year individuals to develop their leadership and management. Wider Considerations 8. Creating a new body such as this may have some effect on demand for existing training and development in the HE sector, and on those who supply it. However, this is a growing market overall and, as the Leadership Foundation will be largely an enabler body sourcing provision from a number of providers, it should help develop the market rather than provide competition to private providers. We will reduce bureaucracy and burdens on universities. This will include Creating a new Task Force chaired by David VandeLinde, to advise us on ways of reducing bureaucracy Bringing forward proposals, with the Privy Council, on reducing the requirements for the Privy Council to approve minor changes in the way universities go about their business Objectives and Options 9. Our overall objectives here are to make it easier for universities both to run their day to day business efficiently and without unnecessary interference, and to take forward changes that they think necessary. 10. More details on our plans for reducing bureaucracy are in the Government response to the Better Regulation Task Force (BRTF) report Higher Education: Easing the burden (2002), published in April 2003. We are currently consulting university administrators on the scope for simplifying the regulation of HEIs through the Privy Council.
Costs and Benefits 11. There are high potential benefits in bureaucracy reduction. PA Consulting’ 2000 Report, Better Accountability for Higher Education, s estimated the “ accountability burden”on HEIs at £250 million. However, each proposal for bureaucracy reduction needs to be looked at on its own merits. 12. Not requiring all changes to go through the Privy Council Office (PCO) could speed up the process of approving amendments by between 6 weeks and 3 months. No inherent costs have been identified here, although our current consultation is testing this assumption - and the number of institutions who might benefit - more fully. Wider considerations 13. None.
We will support institutions to build endowments in a range of ways. We will set up a Task Force to promote corporate as well individual giving. From 2004: * We will increase the help available for the students that need it most, by introducing a new national grant of up to £1,000 a year for those from lower-income families. We will introduce a new grant for part-time students. From 2005: * We will raise the threshold at which loans start to be paid back from £10,000 to £15,000 a year, to make repayment less burdensome. From 2006: * We will give universities the freedom to set their own tuition fee, between £0 and £3,000 per annum. But no student or parent will have to pay any fee up-front. A new Graduate Contribution Scheme will allow them to pay their contribution back, through the tax system, once they are earning. * We will safeguard access by having a maximum level for the graduate’ contribution; by requiring institutions to develop strict s Access Agreements; and by introducing a maintenance support grant of up to £2,700 for those from lower-income backgrounds. Raising the contribution from students, whilst protecting access Objectives and options 14. The Government’ proposals, refined since the original White Paper s following wide discussion and consultation, are a package. They consist of:
* *
Freedom for universities to set their own tuition fees, between £0 and £3,000; Abolishing up-front tuition fees for full-time undergraduates, and enabling these students to defer the repayment of any tuition fees charged by their HEI, by providing loans for fees on a subsidised income contingent basis A new national grant of up to £1,000 a year from 2004/05, for those from low income families. This will be rolled together with the funds from the existing fee remission grant to create a new maintenance grant of up to £2700 in 2006/07; Safeguards for access, by requiring institutions charging tuition fees higher than the standard level to draw up an Access Agreement, for approval by the Office for Fair Access; Raising the threshold at which student loans start to be paid back from £10,000 to £15,000; Raising the maximum rate of the student maintenance loan to match the basic living costs expenditure of the mid-range student; Writing off outstanding student loan balances left unpaid 25 years after graduation; and Introducing new grants for part-time students.
*
*
* * * *
15. In drawing up these proposals, the Government had the following broad objectives: * * To allow the HEI sector to develop in ways that give more choice to students when they select their course and institution To give institutions the freedom to set their own prices and manage their own business, in the way they already do for part time and overseas graduates and in a way that is tried and tested overseas To raise additional money for institutions where the benefits can be justified by the quality and the expected returns to students To protect and promote access to higher education for the most vulnerable members of society The Government has taken four key propositions as given: * * Universities need more money, above existing government spending plans Additional funding should include a contribution from the students who benefit
* * 16.
*
It is desirable for full-time undergraduates to receive higher education that is free at the point of delivery, with the students’contribution paid after they have graduated, through the tax system, with repayments linked to income Students from low-income families need extra help
*
17. The Government therefore had various objectives to meet, and any valid appraisal of our proposals needs to take this into account. For example, had we solely wished to give more public funding to higher education institutions, there would have been some simple ways to achieve this. Equally, our proposals to support low income students are not the inevitable consequence of our proposals for variable fees. We were seeking to support choice, freedom, quality and access; not to favour one at the expense of the rest. 18. In looking at how to meet its broad objectives, the Government particularly considered three alternative approaches; an increase in the standard fee, the introduction of a graduate tax, and whether to charge graduates a real rate of interest on their student loans. Increase in flat-rate fees 19. An increase in the flat-rate standard fee would mean that all students had to pay more towards their higher education, regardless of where or what they studied. The Government decided against this approach on the grounds that it would be less effective in increasing choice for students; increasing autonomy for HEIs; and improving the overall quality of higher education. More details about the Government’ thinking is in a DfES briefing paper, s “ Why not a Fixed Fee” placed in the House of Commons Library on 15 , December 2003. www.dfes.gov.uk/hegateway/hereform A graduate tax + universal grant approach 20. A pure graduate tax approach was considered, but had a number of disadvantages, both in principle and in practice. The Government’ reasons s for rejecting this option were set out in its response of February 2003 to the House of Commons Education and Skills Select Committee’ report on Post s 16 Student Support, recommendations 16 and 29. Further details are in a DfES briefing paper, “ Why not a Pure Graduate Tax” placed in the House of , Commons Library on 8 December 2003. www.dfes.gov.uk/hegateway/hereform Real rates of interest 21. A range of variants on the possibility of applying a real rate of interest to student loans was considered, in order to reduce the public expenditure costs. The reasons why these were rejected were set out in detail in the Government’ response to the Report from the House of Commons Education s and Skills Select Committee, published in July 2003. 22. The Government also modelled the effect of charging real rates of
interest in a memorandum for the Committee, available on the Committee’ s website; see
http://www.publications.parliament.uk/pa/cm200102/cmselect/cmeduski/445/2051308.htm
Costs and Benefits 23. While the Government’ proposals are a package, they are not s intended to be introduced simultaneously. On the contrary; they fall in different financial and academic years, and some of them have costs and benefits that do not reach steady state for a very long time. And while some proposals relate directly to the introduction of a variable fee system, others benefit groups who are not affected by this change – for example, part-time students, or undergraduates who are in higher education before autumn 2006. For clarity, we have therefore looked at the costs and benefits of each of the proposals in the chronological order in which it is expected that they will come into effect. Broadly they divide between those that come into effect before autumn 2006, and those which follow the proposed start of variable tuition fees, from autumn 2006 onwards. From Autumn 2004 A new student HE grant of £1,000 24. The costs to Government of funding the £1,000 HE grant for England and Wales will start from the 2004/05 academic year, and build up, cohort by cohort. The new HE grant subsumes the Opportunity Bursaries (OB) scheme, which has operated in Excellence Challenge (now Aimhigher) areas. The money allocated to Opportunity Bursaries in 2003-04 is £18.5 million. Once all the cohorts have fully worked through the system, the steady state cost of the new HE grant would be around £300 million – an increase of just over £280 million net of Opportunity Bursaries. 25. Some administrative costs of implementing the new grant will fall to the Student Loans Company. The SLC will be considering this change and associated development costs alongside all other changes planned for 2004/05. 26. The major benefit of this proposal will be to poorer students. Students whose residual family income is below £15,200 (around 30% of all students) will receive the full £1,000 HE grant. Between this lower threshold and £21,185 there will be a taper where the grant will reduce by £1 for every additional £6.30 of income. 27. Evidence from the first survey of Opportunity Bursary applicants indicates that, compared with students having similar characteristics who were not eligible for, or successful in gaining, an OB: fewer recipients reported feeling unable to continue with their studies on account of the costs; fewer recipients reported being worried about getting into debt; fewer recipients were worried about combining studying with a job; more recipients
were confident about the long-term benefits outweighing the costs of their studies; students who had received OBs reported lower levels of debt than non-recipients. The Government expects to see similar benefits arising from the introduction of the new HE grant. New support for part-time and mature students 28. The part-time proposals are aimed at those on low incomes who are studying the equivalent of at least 50% of a FT course. They comprise a course grant to replace the part-time loan and statutory fee support up to a capped level, which is replacing the discretionary fee waiver scheme administered by HEIs. Making both elements of support statutory will allow students to get a better idea of the support they are entitled to earlier and thus enable them to plan more effectively. 29. We estimate that the number of students who will be eligible to receive full or partial support under the new arrangements will be around 97,000. This compares to approximately 29,000 students who currently receive a fee waiver and 9,500 who are in receipt of the loan. Funding of £49 million is being made available in 2004-05 for the fee and course grants. This includes the funding already set aside for the PT loans and fee waivers, which the new arrangements are replacing. We expect that the basic roles of HEIs, LEAs and the SLC will be as now, under the part-time loan arrangements. LEAs may see some increase in their workloads, but but this should not be great as most of the processing of applications will be automated. 30. Mature students will benefit from many of the changes arising from the White Paper, including the £1,000 HE Grant for lower income students, and the new household income assessment. In particular, mature students will benefit from changes to the income assessment for single, financially independent students. Where currently their support is reduced pound for pound on net income above £7,500, from 2004/05 this will be changed to £1 in £9.50 of gross taxable income above £10,000. Mature students with a partner are also to be assessed more generously. Where a contribution is currently raised at £1 in £8 of income above £18,040, this is being changed to £1 in £9.50 of income above £20,970 from 2004/05. 31. Mature students with children will benefit further. The current post assessment deduction of £83 per dependent child (equivalent to an upfront disregard of £664 for a mature student with spouse) is to be replaced by an up front disregard of £1,000. Furthermore, this disregard is being extended to student income where previously it applied only to spouse and parental income. From April 2005 Raising the threshold at which loans start to be paid back 32. Raising the repayment threshold from £10,000 to £15,000 will apply to all borrowers from April 2005, regardless of when they took out their income contingent student loans. Those with student loan debts who earn less than
£15,000 will no longer be making repayments through the tax system. 33. The proposals affect employers, borrowers (students/graduates), and government. Estimates of compliance costs are listed below. The estimates have been quoted in ranges rather than single numbers to help convey the considerable degree of uncertainty surrounding them. The value of costs and benefits are expressed in 2003 prices. Employers 34. The proposal reduces the number of employees expected to be making repayments through the collection of student loans between 2005 and 2009. Hence compliance costs will be slightly lower for employers between 2005 and 2009, compared with what they would have been if the threshold had stayed at £10,000. The Inland Revenue estimate these savings as up to £3 million per year. From 2010 onwards, these savings are likely to be absorbed by extra costs resulting from more borrowers making repayments. Borrowers 35. Raising the threshold will, for some borrowers, postpone the moment that they have to start repaying their loans. In particular, it will make loan repayments less burdensome for graduates early in their careers. Anyone who never earns over £15,000 will see their repayment postponed indefinitely. However, many students will have paid off their loans, covering both maintenance and fees, within 13 years. 36. All borrowers will benefit from more manageable repayments. The reduction in repayments works out at £450 per year, or £37.50 per month, for people on salaries of at least £15,000. This means it will take longer to repay a given amount of student loan debt than when the threshold was £10,000. However, the Government’ policy not to charge a real rate of interest on the s loan means there is no penalty associated with taking longer to repay. The proposal, discussed below, to write off unpaid student loan debt after 25 years is also relevant. Government and public authorities 37. Raising the threshold from £10,000 to £15,000 will increase the cost of student loans to Government. From April 2010 it is intended that it should increase in line with inflation. However, since the cost of the current loans is assessed on the basis that the threshold will rise in line with earnings growth, there are offsetting savings associated with uprating by inflation instead. The combined effect of the two is expected to be a small net saving in cost to Government over the period during which variable fees will be introduced.
From Autumn 2006 Abolishing up-front tuition fees, and enabling all students to defer the repayment of any tuition fees charged by their HEI 38. This proposal has costs, and benefits, to HEIs, employers, parents, students and government. It interacts with the proposal to allow HEIs to charge variable fees, which is described immediately following. Parents 39. About 65% of parents (of English and Welsh domiciled students) are currently assessed as being liable to make a contribution to tuition fees. English and Welsh HEIs are estimated to have received between £425m and £435m in the 03/04 academic year1 from parental contributions. Under the new arrangements, parents would not have to pay these sums and so will benefit. Students 40. All full-time students will benefit from the right to defer payment of any tuition fees charged by their HEI. The proposal makes higher education free at the point of delivery for this group. Students, while having the right to pay any fees up front (as they are currently obliged to do), will be able to add the costs to their subsidised loan instead and repay them after graduation, once they are employed and earning at least £15,000. Further details about the rates of repayment for students as their earnings change are in a DfES briefing paper, “ Student loans and the question of debt” placed in the House , of Commons Library on 17 December 2003 (available online at www.dfes.gov.uk/hegateway/hereform). 41. This may particularly help some students whose parents are assessed to pay some or the entire tuition fee; there is evidence from the 2002/03 Student Income and Expenditure Survey that a significant proportion of parents are not paying their full assessed amount and students are paying the money themselves. Government and Public Authorities 42. There will be a cost to Government of providing loans for fees on the subsidised income contingent basis. Fee deferral will be available for all students from autumn 2006, whereas variable fees would only apply to new students. Students taking a gap year during 2005/06, entering in 2006/07, will be treated as continuing students rather than as new students. Hence, for the first year or two, the greater part of the cost to Government is likely to come from the fee deferrals of students who are still liable for the current flat rate fee, and it will be some years before these students have completely worked through the system.
All estimates relating to fee income are provisional. Firmer forecasts of fee income will be available following the publication of the HEFCE Grant Letter for 2004/05.
1
43. The costs2 to Government of loan deferral vary with the total amount of loans granted. Here we are considering the costs associated with the entire package - that is, the enhanced maintenance loan, the 25 year repayment cap and the deferred higher fees net of fee remission. In analysing the costs of the components of the student support package, the maintenance loan is assumed to be paid back first, with the deferred fees repaid subsequently. The cost per £100 of maintenance loan advanced is estimated to be around £29 – i.e. 29%. As deferred fees are assumed to be repaid only after the maintenance loans are paid off, the cost is higher, at 42%3. 44. The costs of providing fee deferral for the current standard fee only, expected to reach £1,200 by 2006/07, are around 37%. The total cost to government depends on the extent of take up of fee deferral: * If 80% of students took out fee loans to defer the current standard fee, the loan advanced would be around £450m and the cost to the Government would be approximately £165m If 90% of students took out fee loans to defer the current standard fee, the loan advanced would be around £510m and the cost to the Government would be approximately £190m
*
HEIs 45. HEIs will make administrative savings from the proposal to allow students to defer fees. Where students choose to defer their fees, the money will be provided up-front to the institution by the SLC, thereby simplifying the process of collecting fees for the HEI, and reducing the associated costs, since the Government bears the cost of debt collection, including the costs of late payment and bad debts. When student contributions to tuition fees were introduced in 1998/99, HEFCE estimated these costs at 5% of the total student fee income (around £20 million at that time), and this figure was added to institutions’baseline funding. Employers 46. The possibility of deferring fees will mean that students who take advantage of this are more likely to enter employment with loan debts. From 2010 onwards the numbers of borrowers making repayments as employees increases. Employers are already helping to administer loan repayments, via the tax system; the costs of their doing this will also gradually start to rise from 2010. Steady state may be reached some time between 2020 and 2030, at which point the overall costs, spread between all the employers of graduates, are estimated (in 2003 prices) at up to £15 million higher per year than under
The Resource Accounting and Budgeting (RAB) charge. This 42% figure is the combined cost of providing loans for the current standard fee and the additional fee loan up to £3,000. When looked at separately the costs differ (as referred to in paragraph 52). The current standard fee loan is treated as being repaid first and thus costs less than does providing the additional fee loan up to £3,000 (which is treated as being repaid last). The combined cost is between the two.
3
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the current arrangements. We will seek to streamline the processes for employers as much as possible. Freedom for universities to set their own tuition fees, between £0 and £3,000 47. The various costs and benefits associated with this proposal interact with the proposals for deferral, described above. Because of the nature of a variable scheme, the costs vary greatly according to the decisions that institutions take, and they cannot be estimated precisely at this stage. HEIs 48. For HEIs, this proposal will change the environment in which they operate. They will want to develop pricing and marketing strategies for their courses, and may want to review these regularly, at least in the early phases. Both these will bring some administrative costs; how much will depend on how elaborate and varied a strategy they choose to pursue. An institution which decided not to charge fees higher than its current levels could incur virtually no extra costs. 49. The main benefits to HEIs of this proposal will be the increased autonomy it offers them, and the potential extra fee income raised as a result of charging variable fees. HEIs charging the maximum fee could raise an additional £1,800 per student per year of study (this being the difference between the maximum variable fee of £3,000 and the estimated standard fee of £1,200, and making reasonable assumptions about where inflation will have taken the standard student fee by 2006/07). This money should help HEIs to improve the overall quality of their institutions, and to further their individual missions. Some of these benefits will be offset by the costs of Access Agreements – these issues are discussed more fully in chapter 6. 50. If HEIs had been able to charge a maximum tuition fee of £3000 in 2003/04, the following two scenarios illustrate the additional income for English HEIs. (These same two scenarios are also used elsewhere in this paper.) * If 75% of HEIs had charged the full £3,000 proposed maximum fee and 25% charged the standard fee, the approximate fee income to English HEIs would have been between £1,780m and £1,820m, of which between £990m and £1,010m4 5 would have been over and above existing fee income. If 50% of HEIs had charged £3,000 and 50% the standard fee, the approximate fee income to English HEIs would have been between
*
This is in addition to fee income to universities from the standard fee of £1,125 in 2003/04, not including full time post graduates (apart from PGCE students). All figures are for students at English HE Institutions for 2003/04.
5
4
All estimates relating to fee income are provisional. Firmer forecasts of fee income will be available following the publication of the HEFCE Grant Letter for 2004/05.
£1,450m and £1,490m, of which between £660m and £680m3 4 would have been over and above existing fee income. 51. The additional funding raised will mean an increase of up to 30% on the average funding per student where universities charge the full £3,000. Government 52. Government will bear the up-front costs of paying fees to institutions whenever a student decides to defer payment. The costs of this will vary depending on how many students decide to defer, and what fees institutions charge. The costs build up cohort by cohort and steady state will not be reached before the 2010-11 financial year, though in practice it might take still longer. The pattern of fee charging may take a while to establish itself, as will students’response to it. Students’pattern of decisions on fee deferral, influenced by the extent to which HEIs offer bursaries to help those on lowest incomes, will also take time to develop. So we might expect the costs to government not to reach steady state until some time after 2010-11. 53. The additional steady state costs of deferral, in 2006/7 terms, are illustrated below in the following scenarios, assuming the RAB cost for this element is 44%, since it is assumed to be the last element of loan to be repaid: * If 75% of HEIs charged the full £3,000 fee and 25% charged the standard fee, and if 80% of students took out fee loans, the loan advanced for the additional fee over and above the standard fee would be around £900m and the cost to the public purse would be approximately £395m. If 75% of HEIs charged the full £3,000 fee and 25% charged the standard fee, and if 90% of students took out fee loans, the loan advanced for the additional fee over and above the standard fee would be around £1,010m and the cost to the public purse would be approximately £445m. If 50% of HEIs charged the full £3,000 fee and 50% charged the standard fee, and if 80% of students took out fee loans, the loan advanced for the additional fee over and above the standard fee would be around £600m and the cost to the public purse would be approximately £265m If 50% of HEIs charged the full £3,000 fee and 50% charged the standard fee, and if 90% of students took out fee loans, the loan advanced for the additional fee over and above the standard fee would be around £675m and the cost to the public purse would be approximately £295m.
*
*
*
54. This proposal will also have a small effect on the Inland Revenue and the Student Loans Company. As with employers, the extra costs are largely a function of increased numbers of graduates repaying loans after 2010. Both
organisations will also have to revise their documentation and procedures to allow for new repayment thresholds, and the need to monitor what fees a student is incurring for what courses. Estimated one-off development costs to the IR and the SLC of introducing the change in threshold are around £400,000: DfES and the Devolved Administrations would meet the cost. Replacing the HE Grant of £1,000 with a maintenance grant of £2,700 55. Replacing the HE grant and grant for fees with a single combined maintenance grant is a logical approach to take in a system where fees are deferred and paid back at a rate linked to income after graduation. There is a potential increase in funding needed, because the fee support will be through the loan for fees, and this comes in addition to the new upfront maintenance grant. To offset the additional cost of the extra loans for fees, an element of the new grant will be in substitution for the existing maintenance loan. A discussion paper entitled “ moving toward a single combined grant for higher education” was published in January, and is available from www.dfes.gov.uk/hegateway/hereform. 56. As part of this move, we are increasing the overall value of the grant by £500 compared to the HE grant of £1,000 and the grant for fees. The cost of this increase will be around £120 million a year in steady state. Requiring institutions charging tuition fees higher than standard level to draw up an Access Agreement, for approval by the Office of Fair Access 57. The costs and benefits of this proposal were described in chapter 6.
Raising the rate of the student loan 58. This proposal would raise the maximum rate of student maintenance loan to match the basic living costs expenditure of the mid-range student. This will increase the total amount that students can borrow, to their benefit. The average size of loan is expected to rise by 5% above inflation in 2006/07. There will be a corresponding loss to the public purse, which will fund this extra borrowing. We estimate that the additional steady state RAB costs to Government, on the maintenance loan and fee loan budgets, will be around £65m in 2006/07 terms. 59. Because the average loan size will increase, the average time taken to repay it will increase too. This will prolong the collection of repayments by employers. Because the increase in loan size is small, and repayment is spread over a long period, the impact will be marginal and is not significant enough to add to the costs on employers already identified in this chapter. Writing off loan balances after 25 years 60. The Government intends to write-off outstanding student loan balances (except for arrears) 25 years after graduates enter liability to repay their loans, which is from the April after graduation. This policy will apply to those entering HE from 2006 and graduating in 2009 and cover both maintenance
and fee loans. About 5% of borrowers, starting from 2006/07, may benefit. There will be a corresponding cost to the public purse of monies written off, and we estimate this to be £30m per year in steady state. Summary of costs and benefits 61. The Government’ proposals are a balance of costs and benefits for all s involved. From the public purse, the major up front investment is going into ensuring that higher education is free for full-time undergraduates at the point of delivery, by supporting fee deferral for all students. The second largest cost is in providing significantly greater support for the poorest students, via the HE grant. These are important goals in themselves; they should also be beneficial in improving access to higher education, with the associated improvements in social justice, skills and employability that this would imply. 62. The costs are being met from a mixture of reprioritisation within existing resources, and new money, both spread over a number of years. Strictly speaking, there are virtually no costs directly attributable to introducing variable fees. However, if one regarded fee deferral and loan write-offs as core components of a variable fees policy, then the total cost of variable fees above the current standard level has been estimated above as £475 million (£445 million to defer the higher fee, on the highest assumptions we have used; and £30 million for loan write-off after 25 years). The estimated cash benefit to HEIs, on the same assumptions, is around £1billion. 63. Students, and their parents, are immediate beneficiaries of the investment from the public purse. In the longer term, once students become graduates and earn a reasonable wage, they will take on the responsibility of repaying some of these costs (though not the HE grant). In other words, Government is giving more support to students, to enable them to finance a rather higher proportion of the actual costs of their higher education. The variability of the fees enables students to exercise more control than at present over the costs they choose to take on. 64. Higher Education Institutions benefit from increased freedom and the possibility of increased income if they can attract students willing to commit to higher tuition fees, and can satisfy the Office of Fair Access over their access agreements. Precisely this new freedom will require them to work out how to use it well in support of a coherent and sustainable strategy. Wider Considerations 65. The Devolved Administrations in Scotland and Wales have said that they have no current plans to introduce variable fees. However, their introduction in England would be certain to have some effect on the other parts of the United Kingdom, and the relevant administrations are considering this. 66. In Wales, the National Assembly has announced that it intends to offer fee deferral arrangements on exactly the same terms as will be offered for English domiciled students to any Welsh nationals wherever they study from
2006 onwards. The Assembly Education and Lifelong Learning Minister announced that on Royal Assent of the HE Act an independent review of student support policy and the tuition fee regime in Wales would start under the chairmanship of Professor Teresa Rees. The review will help the Assembly to decide what it might do with its new powers. In particular it will address the question of variable fees from AY 2007/8 onwards. 67. In Northern Ireland, Ministers are considering the potential implications of the Higher Education Act 2004 and will bring forward proposals for the way forward, in due course, following consultation with local stakeholders including the Northern Ireland Higher Education Council (NIHEC). We are simplifying and improving the administration of student support Objectives and Options 68. Four of the interventions under this broad proposal were the outcomes of detailed consultations and proposals by the Targeted Review Working Group. Represented on the Group were a broad range of interests, including NUS and LEA representatives; HEFCE; student money advisors; Hardship Fund administrators; and DfES officials. The four interventions are: The new Parents’Learning Allowance of up to £1,300 This grant consolidates three existing grants to support students with dependent children during their HE studies: the additional dependant grant; the travel, books and equipment grant; and the access bursary. Amalgamating three grants into one makes it easier and more transparent for students. Childcare Grant increased to 85% of actual costs for the full year This is intended to improve childcare support for student parents on low income. Previously the childcare grant covered only 70% of actual costs during the 12 week long vacation. The new discretionary non-repayable Access to Learning Fund, consolidating the Hardship Fund and Hardship Loans The objective of the Access to Learning Fund is to provide simpler and more transparent arrangements for students in financial difficulty and to ensure greater consistency in the assessment process between institutions. Improved discretionary part-time support (childcare for those on fee support and on 50% FT courses; and fee waiver for those on low income and at least 10% FT courses) administered through the Access to Learning Fund This proposal is part of the improved package of support for part-time students, to ensure that we properly support those who study more flexibly. It recognises that childcare costs may be a barrier to participation for part-time students. Providing childcare support through the discretionary, rather than statutory, system allows more flexible criteria to be adopted by the institution. The fee waiver for students studying between 10% and 50% of a FT course allows them to have the experience of higher education where otherwise they
may not be able to due to financial constraints. Costs and Benefits 69. Parents’Learning Allowance will benefit students with dependent children who will receive this grant as an upfront statutory element together with their main student support (i.e. tuition fee and loan) applied for through their LEA. The estimated additional cost of funding this grant (about £8 million) has been transferred from the discretionary to the statutory budget. Consolidating three grants into one means that students now have to make only one application for this support. 70. Increased Childcare Grant in the long vacation will create estimated additional costs in grant payments of £1 million for the DfES. The benefits to the student mean that they have more guaranteed funding available to meet the costs of childcare across the calendar year. It also streamlines LEA administration. 71. The Access to Learning Fund (including improved discretionary parttime support) will provide a more transparent and improved package of support for vulnerable students. Hardship Loans will be amalgamated with Hardship Funds to enable students in financial hardship to receive all their additional support through non-repayable grants. HEIs will benefit from the move to one funding stream for hardship support. We expect that the new standardised assessment will enable institutions to run the Access to Learning Fund more effectively, with a higher proportion of the administration funding being used on student welfare, and less on processing claims. There will be no additional cost to the public purse. Wider Considerations 72. None.
Updating the parental income assessment so that it recognises changes in family patterns Objectives and Options 73. This proposal is intended to target student support more effectively, by taking account of the income available to a household that comes from the cohabiting partner or spouse of the parent with whom the student normally lives. This will make the means-test fairer by ending the current anomaly whereby a family in which the parent’ partner is not the student’ natural parent can s s contribute less than a family with two natural parents, despite their income being the same. 74. The change in means-testing recognises changes in family patterns. It uses the more inclusive definition of household income used in the tax and benefits system and in the Educational Maintenance Allowance means-test. Another option was to means-test the absent parent, rather than the parent’ s co-habiting partner or spouse, but it was decided that this option would
increase the likelihood of non-payment and family friction. Costs and Benefits 75. There will be extra costs from this proposal to families of students with a step-parent or co-habiting partner who would previously have made a smaller contribution to their student’ support. These costs will depend on the s family’ income levels. We estimate that around 10% of dependent HE s students are in households where their parent’ partner is not their natural s parent. 76. Benefits will flow to the public purse from 2004/05. In steady state the annual savings will amount to around £35 million to the Government's fee remission and income assessed loan budgets. These estimated savings are based upon a 60% – 80% compliance rate. 77. The new household income assessment, like the current parental income assessment, will be based on self-declaration of income, and administered by the LEAs in accordance with arrangements already in place for assessing parental contributions. We do not expect it to impact significantly on LEAs’administrative costs. Wider considerations 78. None.
We will reflect the non-commercial nature of the student loan by preventing such loans forming part of a bankrupt’ estate s Objectives and Options 79. Under current legislation student loans are provable in bankruptcy - this means that bankrupt borrowers will have their loans written off. Government policy is, and always has been, that student loan debt should not be written off with bankruptcy. Student loans are different from commercial loans. Borrowers benefit from non-commercial repayment terms (including collection through the tax system), a zero real rate of interest and subsidy from the tax payer. Graduates should not see bankruptcy as an easy route to clearing their debts. 80. We became aware during the passage of the Enterprise Bill in Parliament last year that student loans are written off on bankruptcy The Enterprise Act 2002 reduces some of the negative impacts of bankruptcy on individuals (e.g. reducing the minimum term of discharge). There is concern that borrowers may become more willing to be declared bankrupt to have their debts written off. We are proposing to legislate to close this loophole to reflect the policy intention. Costs and Benefits 81. Other than the administrative costs of preparing legislation, the costs of
this proposal fall on bankrupts owing student loan debts, which would otherwise have been written off. The Student Loans Company has now been notified of around 2,300 student loan borrowers in England and Wales with bankruptcy orders against them. These borrowers have outstanding loan balances of around £10.4 million, which will be due for write-off on discharge.. 82. The benefits will accrue to the public purse. Annual Government spending on student loans is in the region of £2 billion, and this is expected to increase if loans for variable fees are introduced from 2006 as proposed. Even if, as a result of future bankruptcies, only 1% is written off, this would represent a significant depletion of public funds. Wider Considerations 83. The proposal is to treat student loans differently from other debts on bankruptcy, and this may have some effect on the commercial credit industry. We are consulting a range of organisations with an interest in consumer credit and debt and bankruptcy advice. The Insolvency Service of the DTI is working with the Department on this proposal and legislation.
CHAPTER 8 – HIGHER EDUCATION ACT PROVISIONS NOT IN THE HE WHITE PAPER
1. Two areas in the Higher Education Act 2004 were not foreshadowed in the January HE White Paper. They, with their costs and benefits, are discussed below. Taking new powers to share data electronically with other bodies, mainly to save students having to provide the same information repeatedly to different organisations. Objectives and Options 2. This proposal seeks to provide a legal basis for the supply of data to other organisations, as part of the Department’ plans to modernise the s administrative arrangements for student support and the general wider government aims of reducing bureaucracy and delivering joined up government. 3. The student financial support arrangements necessarily require Student Support Authorities to collect a substantial amount of information about students, parents, spouses and others in order to make eligibility and financial assessments. In line with the Government’ objective for the citizen s to provide data to Government only once, we wish to supply the information we collect to other bodies undertaking public functions in order to simplify the interactions of citizens with those other public bodies. As the majority of applicants for student support are young people, making a student support application will be the first time that many of them have had substantive dealings with government. There is therefore significant scope to simplify their future dealings with Government through the supply of data. However, it will be for individuals to decide whether they wish to benefit in this way as we will only pass data to other bodies with the individual’ consent. s 4. Some of the Student Support Authorities do not currently have sufficient legal powers to undertake the range of data sharing currently under consideration. To provide these powers changes to primary and secondary legislation are required. 5. A number of alternative approaches were considered but dismissed for the reasons set out below * Do not pursue data sharing - we could not realise some of the extended benefits in terms of simplifying the process for students and cost savings that could be gained from introducing these proposals. Do not seek legislation - this would limit the options for the supply of data and therefore our ability to simplify the process. Seek general powers via primary legislation to share any data with any organisation as deemed necessary by the Secretary of State – we do not consider this option to be proportionate, and feel that it is more than is required to achieve the aim.
* *
*
Seek specific powers via primary legislation to enable specific information to be shared with specific organisation. This approach would be inflexible, meaning a change in primary legislation to enable each new instance of data sharing.
Costs and Benefits 6. The costs and benefits of implementing each data sharing opportunity will be assessed on a case by case basis and a business case brought forward with any future recommendations. There will no costs to individuals. 7. The benefits of data sharing will include contributing to our aim of providing administrative arrangements that are easy for students to use, simple to administer, “ joined up” flexible and value for money. For example, , many HEIs are likely to be introducing bursary schemes aimed at lower income students. It is possible that there will be benefits to students and HEIs if the income details assessed by LEAs as part of students’applications for statutory student support were to be made available to HEIs directly, so that they can make their decisions on how they wish to operate their bursary system with the minimum of new information being needed from the students or their parents. Wider Considerations 8. The data we give out to other bodies and the purposes for which they can use the data will be prescribed. All data exchanges will be in accordance with the Data Protection and Human Rights Act and will be with the individual’ consent. There is an additional risk that errors in data from one s body will be propagated to another. However, individuals have an obligation to ensure that information they provide is accurate and have right to ensure that any data held by government about them is accurate. Students will also continue to have the right to decline data sharing if they wish to. Devolution of student support to Wales
Objectives and options 9. The Higher Education Act 2004 will transfer certain functions of student support to the National Assembly for Wales. These functions, which include control over the tuition fee regime, have been operated by the Department for Education and Skills (DfES) on an England and Wales basis. Costs and benefits 10. The main external stakeholders are local education authorities (LEAs) and the Student Loans Company (SLC). On transfer of functions, the National Assembly for Wales will deal with both the SLC and LEAs on similar terms to their current relationship with DfES.
11. Some initial costs will fall on DfES and the National Assembly for Wales in arranging for the transfer of functions. 12. Benefits will fall to LEAs, and to the National Assembly for Wales. The National Assembly currently offers the discretionary Assembly Learning Grant (ALG) on a means tested basis to Welsh domiciled students. The ALG is operated outside the DfES administered student support system. LEAs in Wales administer the ALG. From an LEA perspective the burden of running two parallel student support arrangements will be reduced after the DfES administered student support system is transferred to the National Assembly, as the opportunity will arise to embed the ALG within the mainstream student support system. 13. The transfer of functions will bring the devolution settlement in line with that in Scotland and Northern Ireland. The transfer would provide the Assembly with full discretion over the financial levers for higher education in Wales. This will enable the Assembly to operate higher education on a whole system basis, and deliver a student support system that works in tandem with its wider strategy for the sector in Wales. Wider considerations 14. None.
DECLARATION